United States Board of Tax Appeals September 8, 1925, Docket No. 1138 (Appeal of United Metal Spinning Co.)

*521OPINION.

Smith:

The taxpayer claims that it was affiliated with the B. & L. Auto Lamp Co. for the year 1919. This is denied by the Commissioner upon the ground that it owned or controlled only two-thirds of the capital stock of the Lamp Company during the year and that the ownership or control of that amount of stock of its subsidiary is not sufficient to entitle the corporations to file a